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My company supports multiple government agencies at multiple installations of multiple contract types.

The government requires employees who are working in certain positions to have specific training for those positions. We are required to re-train annually.

On some of our contracts we are authorized reimbursement for this training as a direct charge expense and the contract ceiling allows enough for our company to bill these costs.

On other contracts - the costs for this training was not proposed and we have tracked these costs as non-billable to track them against the appropriate objective.

Our controller would like to record the costs of the training courses (on the projects we cannot bill because of ceiling restrictions) as overhead items as employees who take these courses could use this training to support other projects if needed.

Based on FAR 52.203 (:huh: I believe we are limited to either recording these costs as direct or indirect not alternate based solely on whether we can bill or not. I also believe that as these employees take this training in support of a specific contract that these costs are allocable to a single cost objective and am not sure how we could justify charging them across all contracts.

I would like to know if anyone else has ideas as to how we can handle/adjust these costs or good documents to argue my position to the controller. Thoughts??

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I agree with your controller although not because of ceiling restrictions. Certain training/certifications (CISSP, PMP, etc) provide a benefit to the company and employee that extends beyond the contract they are working against. Additionally if these certifications/knowledge is part of the required skill set of the position (esp if key personnel) then it is incumbent upon the contractor to bear the cost.

If the training is so specific that it doesn't apply anywhere else, then it should be charged as an ODC on the contract. Examples of this might include training on proprietary software that is provided as GFP in the contract. If you truly believe that you have this type of training cost and it was unanticipated at time of proposal, then you should request a ceiling increase from the CO. You'll need to explain why you did not anticipate the costs when you proposed - and training replacement personnel because of turnover generally isn't a good enough reason. Neither is "we didn't think of it"

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Does your company have a requirement to file a CAS Disclosure Statement, and if so, what does it say therein about how you accumulate costs for training?

Have you read the definitions of "Direct cost" and "Indirect cost" at FAR 2.101 ?

If you are required to follow CAS 402, then you must consistently charge like costs incurred for the same purpose as either direct or indirect. CAS does not permit you to record costs as indirect just because you can't bill them. in fact, you should never make charging decisions based on lack of budget or inability to bill. In order to treat some training costs as direcrt and others indirect, you need to make the case that these are like costs, but incurred for different purposes, or different costs altogether.

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